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GINITED STATES GOVERNMENT DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE

‘emorandum

TO

FROM

SUBJECT :

PUBLIC HEALTH SERVICE

: RMPS Staff DATE: February 6,1970

: Associate Director for Grant

and Contract Policy, RMPS

Interpretation of National Advisory Council
Recommendations on Grant Applications

The purpose of this communication is to review the role of the
National Advisory Council in evaluating and recommending action
on applications for Regional Medical Programs.

In line with the provisions of Public Law 89-239, no grant may

be made without the recommendation of approval of the National
Advisory Council. These recommendations are made to the Administrator ,
Health Services and Mental Health Administration who has delegated

the responsibility for final action to the Director, Regional

Medical Programs Service. It is he who authorizes and signs awards
which may be for any portion of a grant application or any dollar
figure, as long as both are within that which was recommended for

approval by the Council.

As one step in the effort to improve the delineation of the various
review functions among the Regional Advisory Group, the staff, the
technical panels, the Review Committee, and the National Advisory
Council a slight revision of the terminology used for recording the
recommendation of the various review groups was initiated for the
November/December review cycle. Although no change in the system
of review was proposed, the use of these designations is intended
to focus major attention on Regional programs, even when only
supplemental components are under review. A list of these
designations is attached.

An additional word seems appropriate in regard to the use of the
Council minutes in working with and providing feedback to the Regions.

A. Tt is essential to keep in mind that the Council makes
recommendations to the Director, The final decisions on the extent
of the approvals and funding levels, based on individual applications,
are his and supercede any of the recommendations made by the peer
review groups. The single exception is that he may not award funds

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for anything which the National Advisory Council does not recommend
for approval. It is also important to recall that the final process
of award is not accomplished until the region has had an opportunity
to reassess its own priorities in the light of the information feed-
back from the National review process, has had the opportunity to
consult its Regional Advisory Group, and submits a final budget.

B. Assuming concurrence by the Director, the Council recommendations
on Regional Medical Programs applications are to be interpreted as
follows:

1. Approval. Full funding, in the time and amount requested,

for the entire grant application, with no specific suggestions ,
conditions, or contingencies* on any one of the components.

2. Approval with specific conditions. Funding, in whole or in
part, of at least one of the components of a grant application, in
an amount which is the sum of the amounts recommended for the approved
components (either as requested or specified in the recommendations).

With the exception of those components on which the
recommendation is non-approval or deferral (see below), the total
amount of money recommended for funding may be utilized at the
discretion of the Region for any or all of the projects, as long
as they are not substantially changed in their intent or operation,
and as long as the conditions and suggestions of the reviewers are
taken into account.

3. Deferral. This designation will be used for entire program
application packages only very rarely and usually in instances in
which policy decisions to which the projects relate are still pending
before the Council. This implies no need for alteration or revision
of the proposal or its budget and serves simply to hold the application —
for action consideration in the next or subsequent review cycle.

4. Return for Revision. This recommendation is used to convey
the recommendation for substantial revision of the whole proposal,
to the extent that a new application must be submitted for review
through a complete review eycle.

 

5. Disapproval - Inappropriate for DRMP funding. This designation
is used for total grant applications only when it applies equally to
all components contained therein. It is used rarely, and only in
two instances. One is when the activities proposed are considered
to be either outside the terms of the Program's legislative authority
or previously announced Council-approved guidelines and policy
recommendations. The second use is for applications which are
determined to be based on erroneous scientific concepts, propose
activities which are potentially hazardous to patients, or otherwise
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are not in the best interests of either the providers or the
consumers of the proposed service.

C. When the Council wishes to record a recommendation on a single
project component of an application which is at variance with the
recommendation of the Review Committee, it may do so and the
following designations are used:

 

Approval I - A straight approval, with or without specific
conditions or contingencies*, in either the amount requested or
a reduced amount, with the suggestion of sufficiently high priority
that the base grant to the Region be supplemented with additional
funds for its implementation.

Approval II - Approval, with or without conditions, for
inclusion in the applicant's program, pending the reassessment
of funding priorities by the applicant Region but without the suggestion
of supplementation of the grant with additional funds.

Non-approval I - Inappropriate for DRMP funding on the same
pases as cited above for disapproval of entire program applications.

Non-approval II - (Revision Required) - Not to be implemented
by the Region even by rebudgeting of existing program funds until
a revised application, reviewed through a complete cycle, has been
recommended for approval by the National Advisory Council.

Deferral - As defined above, this recommendation serves to
hold a project in review pending clarification of the intent of
the project itself or of a program policy to which it relates.

 

When the recommendations carry comments, suggestions, or conditions
made during the review process they are transmitted to the Region

to help explain the reasons for the specific action taken, particularly
when the action involves a budgetary limitation. When the action
carries a contingency, it is the responsibility of the staff to

secure in writing the agreement of the applicant to make the necessary °
specific changes in program and/or budget, before the award is

made. This written evidence of concurrence must be returned to the
Council for final approval unless the Council delegates that final
approval to staff.